Uganda Revenue Authority v COWI A/S
Uganda Revenue Authority v COWI A/S (Civil Appeal No. 34 of 2020) [2021] UGCA 134 (18 October 2021)
The court held that Regulation 13 (3) (a) of The Value Added Tax (Amendment) Regulations, 2011, lawfully treats a branch in Uganda and its overseas head office as separate taxable persons for VAT purposes, even though they are part of the same legal entity. This regulatory approach is consistent with the principle of tax neutrality and the destination principle underlying VAT, ensuring parity between domestic and imported services. The services rendered by the head office in Denmark to the Ugandan branch, for which costs were allocated, constituted imported services consumed in Uganda and wer…
Source excerpt
- Value Added Tax
- Imported Services
- Branch Office Taxation
- Corporate Veil Piercing
- Tax Refunds